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#2125388 - 04/06/17 10:31 PM CRA Large Bank
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
So I am totally donzo aren't.
Kind of got the CRA officer job dropped on me. We have been a large bank since January of this year and have no infrastructure or collection of data. I am screwed. Where do I begin? Please help.

I am starting with commercial lending, hit it hard with training and have them collecting data with their credit reviews. What about the retail side? Any ideas on how I capture this data for the previous 4 MONTHS?

Our previous officer had a great method when we were intermediate, they would scramble for 2 weeks, amass all the data and it usually worked out pretty well for them.

I am scared...two weeks notice time???
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#2125401 - 04/07/17 12:12 PM Re: CRA Large Bank Bec
NMB Offline
Gold Star
Joined: Jun 2002
Posts: 255
Southeast Michigan
Don't panic. I have been exactly in your situation. A few suggestions -
1. The first thing I did was work with our software support gurus to pull a monthly YTD report into Excel showing many helpful fields. You may have to work with them to create some new ones. Having dedicated address fields for the geocode address was essential. Also, loan amount (new and renewal), loan date (new and renewal), collateral code, call report code, gross revenue, fields relating to participations, date the loan was actually set up on the system, product type, purchased loan identifier, purpose/use of funds, and anything else you can think of. This will help you review for small business/small farm loans and also look for community development loans.
2. Get very familiar with call report schedule RC-C definitions and especially the glossary definition of loans secured by real estate. At the two bank where I started large bank reporting, there were issues to work out with the call report specialists and the loan set-up people to correct some misconceptions on call report coding.
3. Make sure you have a way to identify renewals so you can delete the second one in the reporting year unless you have an increase.
4. Make sure everyone is using the same rules for the geocode address. We use the "Follow the money" rule. Provide the address where the funds will be used unless it is not property-related. Then it is the business/borrower address.
5. Continue to train, train, train. Make sure proper collateral and call report coding is part of the training. The correct call report is crucial.
6. You will also need to find a way for commercial lenders to identify community development loans. Don't make it too difficult or they just won't do it. I have forms for lenders' use in doing that, but it usually comes down to just getting them to let me know that they have a possibility and then reviewing it myself.

There are other fine points, I think these could be your initial focus. I'll let someone else chime in on community development activities tracking.

Hang in there.
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#2125453 - 04/07/17 03:59 PM Re: CRA Large Bank Bec
ScoutLaRue Offline
Member
Joined: Jul 2016
Posts: 73
I'd like to follow along on this thread. I am newly named CRA officer-- we switched to an ISB from a small bank this year. I am a total newbie to CRA. Currently writing up procedures to identify community development loans. Similar to what NMB said,..worksheet for commercial lenders to complete if they have a possible community development loan, then pass on to me for review. Not sure where to go after that...

I plan to host a training session for all procedures this time next month so I need to get moving myself.

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#2125546 - 04/07/17 09:02 PM Re: CRA Large Bank Bec
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
Let me tell you ScottLaRue, you are already doing well to start now.
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#2125586 - 04/10/17 01:22 PM Re: CRA Large Bank Bec
RR Jen Offline
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RR Jen
Joined: May 2003
Posts: 3,759
Running and riding everywhere ...
We became a large bank this year as well. Bec, I'm curious about your comment on the retail side. What are you trying to capture from them?
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#2128396 - 04/28/17 04:04 PM Re: CRA Large Bank Bec
KelliD Offline
Member
Joined: Jun 2015
Posts: 62
CD Loans - I have a report sent to me for all loans over a million with call codes that we use for CRA. Then I start scrubbing/reviewing to see if they have a CD purpose and if they are in LMI areas. But also know that CD Loans can be located in other income tracts as long as they serve LMI individuals.

Donations - I get a report from accounting on a quarterly basis and review for CRA donations.

Service Hours - I have made up a typeform that I send out to all employees to fill out their volunteer/service hours on a monthly basis. You can use the same typeform and send out monthly reminders.

Someone else handles the investment part so I can't help you there. We are FDIC and use their excel forms as a format for collecting service hours and donattions. Good luck - I've been doing this for 2 years so I know the struggle to learn CRA. You can do it!

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